CATEGORIES OF RECORDS HELD
a. Documentation in terms of legislation other than the Act, where applicable: e.g. VAT registration certificate
b. Employment contracts
c. Domain name registrations
d. Tradename registrations
e. Company documentation
f. Agreements with suppliers
g. Membership agreements
h. Website information (www.fireplaceshop.co.za and www.heatsense.co.za)
Information in terms of (h) above is freely available on Turtle Cove Nine’s websites. The motivation for access to information in terms of (a) to (g) above will be evaluated, upon receipt of a request, in terms of the policy statement below.

POLICY DEVELOPED IN LINE WITH PROMOTION OF ACCESS TO INFORMATION ACT NO 2 OF 2000 AND PROTECTION OF PERSONAL INFORMATION (ACT) OF 2010

1. INTRODUCTION
Turtle Cove Nine (Pty) Ltd is committed to transparency and accountability and thus supports giving access to information to those who need this information but does this within the principle that customers, suppliers, staff and Turtle Cove Nine (Pty) Ltd have rights to protection and privacy. Thus decisions about giving access to any information will always consider the rights of those affected by this access. Where access to the records of Turtle Cove Nine (Pty) Ltd is requested, the requester must show that the information is required for the exercise or protection of a right. There are conditions under which Turtle Cove Nine (Pty) Ltd is enabled by the Act not to give access to information: these are listed below.

2. PURPOSE OF THE ACT
The Act aims to promote disclosure and not secrecy while protecting people’s privacy and confidential commercial information and ensuring effective, efficient and good governance.

3. SITUATIONS UNDER WHICH ONE DOES NOT HAVE TO GIVE ACCESS AND SOME EXAMPLES OF HOW THIS APPLIES AT TURTLE COVE NINE (PTY) LTD
3.1 The requester has not shown that the information is required for the exercise or protection of a right
3.2 Protection of privacy
It is not necessary to give access to personal information (like customer records or names and addresses)if this constitutes a violation of privacy (unreasonable disclosure of personal information)
3.3 Protection of commercial or research information
will not disclose information that will undermine research or commercial activities
3.4 Protection of confidential information covered by an agreement
Turtle Cove Nine (Pty) Ltd will not disclose information if there is an agreement with the person or entity about whom or about which the information is held that it will not do so.
3.5 Protection of safety of individuals and property
Turtle Cove Nine (Pty) Ltd will not disclose information if the disclosure of the information could in any way constitute a risk to the safety of an individual or property
3.6 Protection of existing processes and proceedings
Turtle Cove Nine (Pty) Ltd will not disclose information if any other process or proceedings or application has already started in terms of any other act – in other words, this act cannot be used to undermine any initiated legal or administrative process
3.7 Defense, security and international relations
Access to information that could influence any of the above will be refused
3.8 Proceedings of committees
Turtle Cove Nine (Pty) Ltd is not obliged to give access to the proceedings of committees that make decisions or express opinions
3.9 Requests which are “manifestly frivolous or vexatious or the work involved would substantially and unreasonably divert resources”.

4. SCOPE
The Act (and thus policy of Turtle Cove Nine (Pty) Ltd) applies to all records being held by Turtle Cove Nine (Pty) Ltd. Record means any recorded information regardless of form or medium in the possession or under the control of Turtle Cove Nine (Pty) Ltd whether or not it was created by Turtle Cove Nine (Pty) Ltd. This applies to all records of Turtle Cove Nine (Pty) Ltd whether they came into existence before or after the Act.